PTAB

IPR2017-01895

Amazon.com Inc v. M2M Solutions LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: System and Method for Remote Asset Management
  • Brief Description: The ’358 patent discloses a system for autonomously monitoring and managing a plurality of "consumer device assets" (e.g., security systems, utility meters, laptops) that are registered with and wirelessly connected to a remote computer server platform. The server receives operational and usage data from the assets and sends back management instructions.

3. Grounds for Unpatentability

Ground 1: Obviousness over Saylor and Loughran - Claims 1-3, 6-18, 20, and 23-30 are obvious over Saylor in view of Loughran.

  • Prior Art Relied Upon: Saylor (Patent 6,400,265) and Loughran (Application # 2002/0129107).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Saylor taught the core system of independent claims 1 and 20: a central security server that remotely monitors and manages consumer devices (e.g., home security control panels, mobile phones) over a network. Saylor’s server received operational status (e.g., on/off status) and consumer usage information (e.g., alarm triggers) and sent alerts. Petitioner asserted that Loughran supplemented Saylor by teaching the autonomous management of mobile devices. Specifically, Loughran disclosed a server sending Short Message Service (SMS) messages containing instructions that cause a device to autonomously download and store new data content (e.g., software updates, emails), thereby automatically modifying stored files as required by the claims.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Saylor and Loughran to improve the functionality of Saylor’s system. Both references addressed the common goal of promptly delivering information to mobile users. Loughran’s method of using SMS instructions for autonomous data downloads would have provided a known solution to enhance Saylor’s alert system, allowing devices to receive and store detailed alert information (e.g., images, videos) immediately without user intervention. Furthermore, Loughran taught an "alert module" that could power up a device from a low-power state upon receiving an SMS, addressing a gap in Saylor regarding how powered-down devices receive notifications.
    • Expectation of Success: A POSITA would have had a high expectation of success, as the combination involved applying Loughran's known data delivery technique to Saylor's structurally similar monitoring system to achieve the predictable result of more robust and immediate notifications.

Ground 2: Obviousness over Saylor, Loughran, and Chow - Claims 4, 19, and 21 are obvious over Saylor and Loughran in view of Chow.

  • Prior Art Relied Upon: Saylor (Patent 6,400,265), Loughran (Application # 2002/0129107), and Chow (Application # 2002/0191557).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the Saylor/Loughran combination to address claims requiring specific network technologies. Petitioner argued that Chow taught communications traversing a Virtual Private Network (VPN) for remote access to home or office networks (claim 4). Chow also disclosed using modern wireless standards, including Wideband Code Division Multiple Access (WCDMA) cellular networks and IEEE 802.11b Wireless Local Area Networks (WLANs), as required by claims 19 and 21.
    • Motivation to Combine: A POSITA would add Chow’s teachings to the Saylor/Loughran system to improve network security and performance. Incorporating a VPN as taught by Chow was a known method to provide secure remote access for mobile devices, a clear benefit for Saylor’s security-focused system. Similarly, implementing newer, faster network standards like WCDMA and WLAN, as disclosed by Chow, was a logical and predictable upgrade to improve data transfer speeds for Saylor’s system, which could involve sending large files like surveillance video.

Ground 3: Obviousness over Saylor, Loughran, and GSM Security - Claim 5 is obvious over Saylor and Loughran in view of GSM Security.

  • Prior Art Relied Upon: Saylor (Patent 6,400,265), Loughran (Application # 2002/0129107), and GSM Security (an ETSI-GSM Technical Specification from 1992).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground addressed claim 5, which required that communications be encrypted according to a key pair encryption scheme. Petitioner asserted that the GSM Security standard explicitly taught an optional key-pair encryption scheme for securing communications over a GSM network, the preferred network type disclosed in Loughran. The standard described how a mobile device and the network each generate an encryption key (Kc) from a shared secret, forming a "pair" of keys used to encrypt and decrypt communications.
    • Motivation to Combine: A POSITA would have been motivated to incorporate the encryption scheme from GSM Security into the Saylor/Loughran system to protect the sensitive nature of the data being transmitted, such as images or video from a user’s home security system. As GSM Security itself stated, encryption was needed to provide security-related functions, making it an obvious and well-documented solution for the security application described in Saylor.

  • Additional Grounds: Petitioner asserted an additional obviousness challenge for claim 22, adding Kuskin (Patent 7,185,196) to the combination of Saylor, Loughran, and GSM Security to teach key-pair encryption for communications over the Internet (WLAN).

4. Key Claim Construction Positions

Petitioner argued that the Patent Owner might seek narrow constructions and proposed the following broadest reasonable interpretations, which were central to its prior art mapping:

  • "Consumer Device Asset": Argued to mean "any fixed or mobile electronic device," allowing prior art disclosing devices like security control panels and mobile phones to meet the limitation.
  • "Operational Status Information": Argued to mean "data relating to the performance or functionality of a device asset," encompassing data like on/off status or battery levels taught in the prior art.
  • "Consumer Usage Information": Argued to mean "data relating to an individual's interactions with a device asset or related devices," covering information such as alarm triggers or motion detection events.
  • "Management Instructions": Argued to mean "commands for a device asset to perform particular actions," allowing Loughran’s teaching of an SMS with instructions to download data to satisfy this limitation.

5. Relief Requested

  • Petitioner requested institution of an inter partes review (IPR) and cancellation of claims 1-30 of the ’358 patent as unpatentable under 35 U.S.C. §103.